5292 Tax Procedure - TOWNSEND/HUSSEINI- 12409
John "Jack" Townsend (ADJUNCT)
Richard Husseini (ADJUNCT)
Course Areas: Taxation
Time: 5:30p-7:30p THLocation: 119 TUII
Course Outline: This class covers the procedural aspects of dealing with the Internal Revenue Service, the
agency that administers the federal tax system. The focus is from the private practitioner's
perspective in assisting clients navigate the daunting administrative requirements. The class offers
the following principal subjects:
• Administrative Organization of the IRS.
• The Regulatory Process -- IRS Pronouncements such as Regulations, Revenue Rulings,
Technical Advice Memoranda and Private Letter Rulings
• IRS Audits, including use of IRS Administrative Summonses and Statutes of Limitations
Penalties (Civil and Fraud) and Interest
• IRS Administrative Appeals
• Civil Tax Litigation with the IRS -- Tax Court, District Court, Court of Federal Claims,
Courts of Appeals and United States Supreme Court.
• Collections, including IRS liens and levies
• Federal Tax Crimes, Methods of Proof and Investigative Techniques
• Ethics of Practice in the Tax Procedure Context
Course Syllabus: Syllabus
Course Notes: This is an LL.M class, and JD students may register, if space is available.
Prerequisites: Yes Fed Income Tax
First Day Assignments:
Final Exam Schedule: 12/11 6pm-8pm
This course will have:
Satisfies Skills Course Requirement: No
Satisfies Senior Upper Level Writing Requirement: No
Course Materials (4/1/2014 10:59:38 AM)
No book required for this course
Per professor - text is professors own text: Townsend, Tax Procedure 2012 that is available in pdf format without cost from professors website. See syllabus for website info.